PRIVACY AND DATA SECURITY STATEMENT
Thank you for visiting the online and mobile resources operated by Paleovalley, LLC including https://paleovalley.com, and for viewing this privacy and data security statement. Our privacy statement, contained in the pages that follow, serves to give notice about the types of personal information we collect, how we use it, who we share it with and why, and what we do to try to protect it on our customers, visitors, and any other users. If you are a former or current employee of Paleovalley, please email us at [email protected]
Summary of how we handle Personal Information
What do we collect?
We collect and retain certain personal information from a variety of different data subjects. Our privacy statement applies mostly to those who visit and use our online and mobile resources, from whom we collect very little information unless it is voluntarily submitted to us. You can read here to learn about the categories of personal information we collect.
Why do we use it?
We use personal information received from visitors and users of our online and mobile resources to communicate directly with them, complete transactions, and personalize offers. We provide further detail about our use of personal information here.
When do we share it?
We share personal information when needed to fulfill our legal obligations and when our vendors and business partners need it to perform under the contracts we have with them. We provide further detail about our sharing of personal information here. We do not sell or rent any personal information.
How do we protect it?
We’ve invested in a Security Program that addresses both technical and operational matters. Our program includes incident response and management and vendor oversight components. You can read about those components here and here.
Privacy Choices and Rights
While certain features of our online and mobile resources do require that you provide some personal information, you can choose not to use those specific features and still enjoy the remainder of online and mobile resources. Moreover, you can opt out of certain activities. You can learn more about that here.
Contacting Our Privacy Office
If you have any questions about our privacy and data security policies, procedures and practices, including anything we say in this privacy statement, we encourage you to contact our Privacy Office.
Erie, CO 80516 Email: [email protected]
This privacy statement was amended as of February 23rd, 2023 and is effective as of that date. The English language version of this privacy statement is the controlling version regardless of any translation you may attempt.
NAVIGATING THROUGH THIS STATEMENT
You can use the links below to navigate to areas of this statement that apply specifically to you, or which may otherwise be of interest
Some Important Vocabulary
Where Do We Get Your Personal Information From, What Categories Do We Collect, And How Do We Use It and Share it?
SOME IMPORTANT VOCABULARY
Although not itself a contract, this privacy statement is an important document that explains how we address some of our legal obligations, and your related legal rights, involving personal information. Clarity is therefore important. We’ll use this section to let you know about some words that have special meanings whenever you see them in this statement. Let’s start with the word “statement” itself: when we reference “this statement”, “this privacy statement” and “our statement”, we mean the Privacy and Data Security Statement you are reading now. Wherever we say “Company”, “we”, “us”, or “our”, we mean Paleovalley. We use the words “you” and “your” to mean you, the reader, and other visitors to our online and mobile resources who are, in all cases, over the age of 18. This age requirement is discussed in more detail later in this statement here.
When we talk about our “online and mobile resources”, we mean all websites, portals or other features we operate to allow you to interact with us and our systems, as well as the mobile apps we’ve created and distributed to let you interact with the content we provide and participate in. An “affinity action” is when you “follow” us, “like” us or take a similar or analogous action on our external social media presence.
Finally, and perhaps most importantly, when we refer to “personal information”, we mean any information, data or data element, whether in electronic or other form, that, alone or in combination with other elements, can be used to distinguish, trace, or discover your identity. Certain data privacy laws include specific elements or defined terms for what they consider to be personal information (sometimes also referred to as “personal data”). Where such data privacy laws apply, then the term “personal data” includes the specific elements and defined terms required by such laws.
WHEN AND TO WHOM DOES THIS PRIVACY STATEMENT APPLY?
We collect personal information from the following data subjects:
visitors to, and users of, our online and mobile resources including those who submit information to us;
individuals who sign up to our email subscription or account services; and
those who may interact with our ads and content displayed on third party sites
This statement applies to our processing and sharing of personal information collected from those specific data subjects listed above whenever they visit our website or any other mobile or online resources we may operate.
WHERE DO WE GET YOUR PERSONAL INFORMATION FROM, WHAT CATEGORIES DO WE COLLECT, AND HOW DO WE USE AND SHARE IT?
Categories of Sources - where do we get your personal information?
We collect and otherwise obtain your personal information in the following ways:
when you choose to give it to us by voluntarily submission;
through automatic collection through technical means when you visit or use our online and mobile resources or visit one of our physical store locations equipped with security cameras or similar surveillance equipment;
it may be provided by external sources to us as part of a service for which we engaged that source, such as marketing companies, advertising companies, social media companies and/or companies that provide services on our behalf who, in each case, may have previously and separately collected elements of your personal information without our involvement and then shared it with us.
Voluntary Submissions. Here are some of the ways you voluntarily give us your personal information:
Emails and Texts – If you choose to send us an email from our “contact us” link or a similar link, you will be giving us your email address and any other personal information that may be in your message or attached to it. The same is true if you send us a text message.
Creating Customer Service Portals or Other Accounts – If you create an account with us you will be giving us at least your email address and potentially other identifiers.
Signing up for Newsletters – Similar to account creation, we collect some voluntarily submitted information if you sign up to receive a newsletter or other informational or marketing material we publish.
Registering for Events – When you register for events or programs we may host, you will be submitting certain identifiers. If the event requires a fee, we may also ask you to submit credit card or other financial information.
Community Features – Some of our online and mobile resources may offer social media-like community features letting users post messages and comments, and/or upload image or other files and materials. If you choose to make use of these features, the information you post, including your screen name and any other personal information, will be in the public domain and may not covered/protected by this statement.
If you prefer we not receive the above-described personal information, please don’t submit it. This means you shouldn’t participate in the applicable activities on, or use the applicable features available from our online and mobile resources. Such participation and use is strictly your choice. By not participating, you may limit your ability to take full advantage of the online and mobile resources, but most of the content in our online and mobile resources will still be available to you and we never discriminate on the basis of how much information your provide.
Automatic Collection. When you visit or use our online and mobile resources, information about your internet/electronic activity is automatically collected through your browser via tracking technologies, such as “cookies.” Cookies allow us to collect your IP address along with other identifiers and recognize your computer or mobile device and store some information about your preferences for using our online and mobile resources or past actions, such as:
the type of browser and operating system you use;
the date and time and length of your visit;
the pages visited, graphics viewed and any documents downloaded; and
links to other sites you accessed from our online and mobile resources or used to navigate to our online and mobile resources.
If you access our online and mobile resources from a phone or other mobile device, the mobile services provider may transmit to us certain information such as uniquely identifiable mobile device information. That, in turn, allows us to collect mobile phone numbers and associate them with the mobile device identification information. Some mobile phone service providers also operate systems that provide a proximate estimate of the physical location of devices and we may receive this proximate geolocation data as well.
In addition, when you use our online and mobile resources, we may allow third party service providers to place their own cookies or similar technologies in order to engage in the same types of collection we describe above. For example, we use third party “web analytics” services such as those offered by Google Analytics. For more information on how Google specifically uses this data, go to www.google.com/policies/privacy/partners/. You can learn more about how to opt out of Google Analytics by going to https://tools.google.com/dlpage/gaoptout.
Do Not Track (DNT) is a privacy preference that users can set to have their Internet browser automatically send a signal to our online and mobile resources to request we not track browsing activity across different sites. There is, however, currently no universal standard for sending and receiving DNT signals. As such, we cannot promise that we respond to all DNT signals, but do recognize and respond when required by applicable privacy laws, such as when HTTP header fields or Java objects are used.
External Sources. We may work with companies who make data, including personal information, available so that companies like us can tailor our services to audiences who have the most interest. We also may work with digital advertising and marketing companies to provide you with ads that meet your interests and that enhance your experience with us. These ads may be displayed on websites or device applications operated by third parties. These third parties collect information with their own cookies, pixels, and related tracking technology and then provide that information to us. We are not responsible for their data collection practices. For more information, please see the section “When/To Whom Do We Share Your Personal Information”
If you have questions about how those apps, sites and platforms collect and use personal information, you should carefully read their privacy policies and contact them using the information they provide. In addition, certain coalitions of advertisers allow consumers to opt out of receiving interest-based advertising from members of those coalitions. You can follow the links below to opt out of receiving interest-based advertising from members of these coalitions. You will need to exercise these opt outs on each browser on each device for which you wish to opt out of interest-based advertising.
of Data – what types of personal information do we collect?
The categories of personal information we have collected from visitors and users of our online and mobile resources in the previous 12 months, and may collect from you, are as follows, some elements of which, may be considered “sensitive information” under applicable law:
General Identifiers such as a real name, account name alias, postal address, signature or unique personal identifier, job title and employer, physical characteristics or description, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Financial Data such as bank account number, credit card number, debit card number, or any other information needed to complete with us a transaction that involves payment
Protected Characteristics such as language preference age and the like.
Commercial Information including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet Activity Data or other similar electronic network activity information, such as browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement regardless of device type used be it a personal computer, cell phone or other mobile device.
Geolocation Data such as global position data, commonly referred to as “GPS location” of mobile devices.
Inference Data drawn using the above-described personal information to create a profile reflecting our customers’ preferences.
does not actively collect any sensitive personal information about of
Why Do We Process Your Personal Data?
We use the personal information we collect only in the manner and through the means allowed by applicable law.
Conducting Surveys – We do this to understand the demographics and interests of our customers and website visitors. Paleovalley regularly processes General Identifiers, Financial Data, Protected Characteristics, Commercial Information, Internet Activity Data, Geolocation Data, and Inference Data for such purposes.
Creating Customer Profiles - We do this so that we can engage with you as our user. Paleovalley regularly processes General Identifiers, Financial Data, Protected Characteristics, Commercial Information, Internet Activity Data, Geolocation Data, and Inference Data for such purposes.
Transaction processing –We do this to process, complete, and maintain records on transactions. Paleovalley regularly processes General Identifiers, Financial Fata, Commercial Information, and Inference Data for such purposes.
Technical security – We do this to monitor our networks and detect security incidents. Paleovalley regularly processes General Identifiers, Internet Activity Data, and Inference Data for such purposes.
Improving our Products and Services – This includes internal research and analytics to improve user experience on our online and mobile resources as well as our product feedback. General Identifiers, Financial Data, Protected Characteristics, Commercial Information, Internet Activity Data, Geolocation Data, and Inference Data for such purposes.
Debugging – We do this to debug, identify, and repair errors that impair existing intended functionality of our website. Paleovalley regularly processes General Identifiers, Internet Activity Data, Geolocation Data, and Inference Data for such purposes.
Performing Contracts – such as fulfilling our duties and exercising our rights under contracts we may have with you, our vendors and supply chain partners. Paleovalley regularly processes General Identifiers, Financial Data, Commercial Information, and Inference Data for such purposes.
Verification - We process this so as to verify and respond to consumer requests. Paleovalley regularly processes General Identifiers, Financial Data, Commercial Information, Internet Activity Data, Geolocation Data, and Inference Data for such purposes.
Product safety - We process this so we can provide important safety information and notice of product recalls. Paleovalley regularly processes General Identifiers, Financial Data, Commercial Information, Internet Activity Data, Geolocation Data, and Inference Data for such purposes.
Customer service - respond to consumer inquiries, including requests for information, Customer Support online, phone calls, and in-store inquiries. Paleovalley regularly processes General Identifiers, Financial Data, Protected Characteristics, Commercial Information, Internet Activity Data, Geolocation Data, and Inference Data for such purposes.
Detecting and preventing unlawful acts or Fraud – We process this protect against malicious or illegal activity and prosecute those responsible. Paleovalley regularly processes General Identifiers, Financial Data, Protected Characteristics, Commercial Information, Internet Activity Data, Geolocation Data, and Inference Data for such purposes.
Subscription servicing – We process this so we can facilitate and service your subscription to our mailing list or accounts. Paleovalley regularly processes General Identifiers, Financial Data, Protected Characteristics, Commercial Information, Internet Activity Data, Geolocation Data, and Inference Data for such purposes.
Promotions – such as provide personalized promotions and special offers. Paleovalley regularly processes General Identifiers, Financial Data, Protected Characteristics, Commercial Information, Internet Activity Data, Geolocation Data, and Inference Data for such purposes.
General marketing – including provide users with information about our brand, products, and events. Paleovalley regularly processes General Identifiers, Financial Data, Protected Characteristics, Commercial Information, Internet Activity Data, Geolocation Data, and Inference Data for such purposes.
Tailored marketing – to provide user with marketing tailored to their interests. Paleovalley regularly processes General Identifiers, Financial Data, Protected Characteristics, Commercial Information, Internet Activity Data, Geolocation Data, and Inference Data for such purposes.
Retention of Your Personal Information.
We store and retain your personal information in accordance with applicable law and as long as necessary to carry out the purposes described above and in accordance with our internal data retention procedures. The criteria used to determine the retention periods include:
how long the personal information is needed in connection with the purposes for which we use it;
the type of personal information collected; and
whether we are subject to a legal, contractual or similar obligation to retain the personal information (e.g., mandatory data retention laws, government orders to preserve personal information relevant to an investigation, or personal information that must be retained for the purposes of litigation or disputes).
When/With Whom Do We Share Personal Information?
Over the past twelve months, Paleovalley may share your personal information as listed below:
corporate affiliates and franchisees - We may share personal information with our corporate affiliates, corporate parents and franchisees who will use such information in the same way as we can under this statement.
law enforcement or government - We may disclose personal information to government agencies and authorities, and to other third parties when compelled to do so by such government authorities, or at our discretion or otherwise as required or permitted by law, including responding to court orders and subpoenas.
harm prevention - We also may disclose personal information when we have reason to believe that someone is causing injury to or interference with our rights or property, or harming or potentially harming other persons or property.
successors for business sale/purchase - If we, or any of our affiliates, sell or transfer all or substantially all of our assets, equity interests or securities, or are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, divestiture, consolidation, or liquidation, personal information may be one of the transferred assets.
marketing support vendors – We may need to disclose certain of your personal information to vendors who we have engaged for technology and services that support our marketing efforts.
promotional or fulfillment vendors – In order to carry out promotions we make available to you and/or deliver our goods and services, we are required to share personal information with vendors who specialize in those activities.
software and technology vendors – Our various service providers may have access to or be provided with some of your personal data in connection with the tasks they perform on our behalf such as maintaining portions of our networks or the software applications that run on them.
transaction support vendors / payment processors - We share personal information with those of our vendors and business partners who need it to perform under the contracts we have with them. As part of our Security Program, we have adopted standards for those vendors and business partners who receive personal information from us. We attempt to bind such vendors and business partners to those standards via written contracts. Such standards include expectations that when we share personal information with our vendors and business partners, they will comply with all applicable privacy and data security laws and regulations and our Security Program, and will contractually require and cause their subcontractors and agents to do the same. For any personal information our vendors and business partners process or store at their own locations, we further expect them to use technology infrastructure meeting, at least at the facilities level, minimum recognized standards for security controls. Such recognized standards include those published by the International Standards Organization, the National Institute of Standards and Technology or any reasonably equivalent standards. Please note, however, that we cannot guarantee that all of our vendors and business partners will agree to the above-described contractual requirements; nor can we ensure that, even when they do agree, they will always fully comply.
Paleovalley does not sell your data in exchange for monetary consideration. In order to support tailored advertisements, offers, or content that you may find interesting when you browse the internet, Paleovalley shares certain personal information with our trusted third party partners that support online advertising, data co-operatives, mobile advertising, data analytics, social media engagement, data brokers advertising networks or any other activity that may be considered cross-behavioral advertising. This transfer could be defined as a sale, sharing for cross-context behavioral advertising or targeted advertising.
In support of the activities listed above, over the past twelve months, Paleovalley has shared or sold the following categories of personal information: (i) identifiers, (ii) inference data, (iii) user activity, (iv) commercial information, (v) demographic data, (vi) contact information, (vii) user account information, (viii) proximate location data, and (ix) professional data. For more information on how to exercise your rights in relation to the sharing or sale of your personal information, please see the section “Your Rights under Comprehensive Privacy Law” below.
HOW DO WE PROTECT COLLECTED PERSONAL INFORMATION?
We have adopted, implemented and maintain an enterprise-wide corporate information security and privacy program that includes technical, organizational, administrative, and other security measures designed to protect, as required by applicable law, against reasonably anticipated or actual threats to the security of your personal information (the “Security Program”). Our Security Program was created by reference to widely recognized industry standards such as those published by the International Standards Organization and the National Institute of Standards and Technology. It includes, among many other things, procedures for assessing the need for, and as appropriate, either employing encryption and multi-factor authentication or using equivalent compensating controls. We therefore have every reason to believe our Security Program is reasonable and appropriate for our business and the nature of foreseeable risks to the personal information we collect. We further periodically review and update our Security Program, including as required by applicable law.
Our Incident Response and Management Plan
Despite the significant investment we’ve made in, and our commitment to, the Security Program including enforcement of our vendor and service provider oversight procedures, we cannot guarantee that your personal information, whether during transmission or while stored on our systems, otherwise in our care, or the care of our vendors and business partners, will be free from either failed or successful attempts at unauthorized access or that loss or accidental destruction will never occur. Except for our duty under applicable law to maintain the Security Program, we necessarily disclaim, to the maximum extent the law allows, any other liability for any such theft or loss of, unauthorized access or damage to, or interception of any data or communications including personal information.
All that said, as part of our Security Program, we have specific incident response and management procedures that are activated whenever we become aware that your personal information was likely to have been compromised. Those procedures include mechanisms to provide, when circumstances and/or our legal obligations warrant, notice to all affected data subjects within the timeframes required by law, as well as to give them such other mitigation and protection services (such as the credit monitoring and ID theft insurance) as may be required by applicable law. We further require, as part of our vendor and business partner oversight procedures, that such parties notify us immediately if they have any reason to believe that an incident adversely affecting personal information we provided to them has occurred.
Federal law imposes special restrictions and obligations on commercial website operators who direct their operations toward, and collect and use information from children under the age of 13. We take those age-related requirements very seriously, and, consistent with them, do not intend for our online and mobile resources to be used by children under the age of 18, and certainly not by anyone under the age of 13. Moreover, we do not knowingly collect personal information from minors under the age of 18. If we become aware that anyone under the age of 18 has submitted personal information to us via our online and mobile resources, we will delete that information and not use it for any purpose whatsoever. We encourage parents and legal guardians to talk with their children about the potential risks of providing personal information over the Internet.
SUBMITTING INFORMATION FROM OUTSIDE THE UNITED STATES
Paleovalley takes privacy seriously. Where applicable, data subjects have certain rights which they can request for Paleovalley to fulfill. These request can be made by either the data subject or an authorized agent. These rights include:
The Right to Know. You have the right to request that Paleovalley disclose the personal data that Paleovalley has collected about you;
The Right to Amend. You have the right to correct any information that Paleovalley stores about you;
The Right to Delete. You have the right to request that Paleovalley delete information that it maintains about you, subject to certain exceptions; and
The Right to Opt Out Of Your Personal Information Being Sold or Shared. You may opt-out of Paleovalley sharing or selling your information.
In order to exercise any of the rights detailed above, please email [email protected] . We will use your email as proof of verification unless otherwise prohibited. Exercising your rights under this section will not result in any discrimination by Paleovalley. We will treat you the same as any other user.
If you disagree or dispute a decision that has been made on the scope or application of the rights described in this clause, you may appeal this decision by contacting [email protected]
CHANGES TO THIS PRIVACY STATEMENT
We reserve the right to change or update this statement from time to time. Please check our online and mobile resources periodically for such changes since all information collected is subject to the statement in place at the time of collection. Typically, we will indicate the effective/amendment date at the beginning of this statement. Where Paleovalley determines that such changes materially affect your privacy rights, we will provide additional notice to you. If we feel it is appropriate, or if the law requires, we’ll also provide a summary of changes we’ve made near the end of the new statement.
You have the right to lodge a formal complaint with your supervisory authority. However, you may also reach out to us directly. If you have questions about our privacy statement or privacy practices, please contact our Privacy Office:
Erie, CO 80516 Email: [email protected]